The RSPCA Intention was always to STEAL (seize) all of Geraldine Robertson's world famous pedigreed Neiger Poodles. 

Geraldine Robertson's World Famous Pedigreed Poodles were stolen by RSPCA. RSPCA and their lawyers make massive profits from seizing animals. RSPCA are a competitor in the Pet Industry and use their Political Power for Restraint of Trade activities. 

The warrant said the RSPCA could inspect Geraldine Robertson's property  "for sick and injured animals" and for "conditions". This was not done. There were no veterinarians with the RSPCA inspectors to inspect for sick and injured dogs. RSPCA refused Geraldine Robertson's requests for her vet or any vet to inspect and microchip her dogs prior seizure. There was no inspection of the dogs before the seizure was ordered by Shayne Towers-Hammond. From when the warrant was served on Geraldine Robertson to when Shayne Towers-Hammond arrived (Lawrence Stageman's Tape recording) Geraldine Robertson had been pleading her case with Lawrence Stageman. The entourage of some 20 RSPCA staff, four Council Staff and Imagination Television (Animal Rescue - TV Channel 7) camera crew (Council witnesses), Courier and Sunday Mail had waited around till Shayne Towers-Hammond arrived and the seizure could begin.

The RSPCA had no intention to return Geraldine Robertson's dogs. Their receipt did not properly identify Geraldine Robertson's pedigreed poodles. Section 150 of the Animal Care and Protection Act 2001 states that the receipt should properly identify the animals seized. The RSPCA seized Geraldine's dogs with malice and intent to steal. The RSPCA refused Geraldine Robertson access to her dogs.

Then the RSPCA set about bullying Geraldine Robertson into giving up her legal rights to Appeal for the return of her dogs. They orchestrated a media campaign that brought intensive public pressure against Geraldine Robertson resulting in many months of harassment phone calls, visits at her property from people there to abuse her, threaten and assault her, including being hit on the head with a bottle and many times having piles of rubbish dumped in her drive way. The Internet forums like dogzonline.com.au were used extensively to further incite violence and in fact did incite violence against Geraldine Robertson. 

When the RSPCA learned that Geraldine Robertson was going to Appeal to have her dogs returned, RSPCA again raided her property just before the Appeal time expired and seized her computer system and all her evidence. They punished her by stealing $thousands in cash, stealing her wedding ring and other valuable jewelry and other property including very expensive chandeliers, and keepsakes. The RSPCA took her legally privileged documents that they had no right to. None of these items seized were used in the Magistrate Court Appeal Hearing. Then in many RSPCA witnesses affidavits they said what they did not see, things like the dogs were not cramped in the transport trailers, they did not see any dogs vomiting, no dogs were harmed by RSPCA staff in their removal, things that could only have been prompted by their knowledge of Geraldine Robertson's Appeal. RSPCA inspectors Tracey Jackson, ex cop, RSPCA Prosecutor of SE Qld, and Daniel Young visited Geraldine Robertson's witnesses, intimidated and threatened them. 

Anthony Deane of Clayton Utz (RSPCA Lawyers) played his part. The RSPCA have no power under the Animal Care and Protection Act 2001, only their employees are appointed as inspectors under the Act and Michael Pecic had the delegated power to administer the Act. It was the DPI that Geraldine Robertson had to be Appealed to for the return of her dogs. This did not stop Anthony Deane from presenting as having the power to deal in this matter. In this process he consumed $100,000.00 of Geraldine Robertson's funds negotiating with Geraldine Robertson's lawyers when he had no power to negotiate. It was only the DPI that could return Geraldine Robertson's dogs.

The Appeal was to the Department of Primary Industries and Fisheries (DPI), not to RSPCA. Anthony Deane caused a massive waste of Geraldine Robertson's funds. But worse, Anthony Deane threatened further raids if Geraldine Robertson continued to earn an income from conducting her boarding business.  

 RSPCA had already sold most of Geraldine Robertson's dogs after seizure.  RSPCA then had to provide DPI with "evidence" to get DPI to forfeit Geraldine Robertson's dogs to RSPCA, to enable RSPCA to legally sell Geraldine Robertson's dogs for RSPCA's own profit. DPI Liaison Officer with RSPCA, Fiona Ferguson an ex employee with Department of Public Prosecutions admitted at the witness box that DPI forfeits all seized dogs to RSPCA to be sold for RSPCA profits.

RSPCA failed to deter Geraldine Robertson in her cause to get her dogs returned.

To make out the RSPCA case the conditions had to be really bad for animals so there had to be a putrid smell. Wet concrete had to become a sludge of faeces and urine, massively heavy rain runoff washed debris became a sludge of faeces and urine. Puppies ready for export that had just been playing in the rain had to become urine soaked. The newspaper litter and some dust that had accumulated in the preceeding drought had to become urine and faeces, and the dust had to come from broken up dry faeces. Wet paws had to become urine burnt paws embedded in feces. Felting, something that happens quickly when poodles get wet, had to become bad for the dogs.

The RSPCA veterinarians and kennel staff made only two entries into their computer system animal recording system in the days following seizure indicating there were only two minor problems with Geraldine Robertson's dogs that they found. Look through their Vet Records for incidents from upto two weeks after 9/1/08. Everything from two weeks after the 9/01/08 were caused by RSPCA kennel mismanagement and neglect, not by Geraldine Robertson.  One of these problems was RSPCA caused. The particular dog required pain killers for skin problems typical of clipper burns. RSPCA veterinarians then had to invent evidence. A dog they called Ned (Geraldine Robertson's Jack) had to have maggots on him as he was one of the 3 heavily pelted dogs. The video of this dog at the kennels on arrival before his maggots and clipping was also made available to Geraldine Robertson through an RSPCA oversight. That the RSPCA put the maggots onto this dog is proven. Three puppies that died in RSPCA care had to have died from Geraldine Robertson's neglect. They died three weeks after seizure and were wormed by Geraldine Robertson before seizure and the RSPCA again after seizure but, according to RSPCA Vet Anne Chester, these puppies died from complications related to hook worm. Geraldine Robertson states it was RSPCA neglect that the puppies died from because these puppies had not been weaned and would have needed a special diet. They died from starvation. The Qld University Autopsy Report together with RSPCA Report heavily indicated that. NOTE: RSPCA had available to them numerous older dogs medical reports. It is highly unlikely that a puppy of 8 weeks would clearly show Diabetics symptoms according to Vet Calum Robertson in the witness box. Geraldine Robertson did not own or bred a diabetic dog since she 1st started breeding in 1988.

A dog called Sandy had to have an ear infection caused by Geraldine Robertson. 

The RSPCA claimed that felting was a problem for the dogs when the video supplied shows these dogs happily bouncing around excited by all the attention they are getting. They were happy healthy dogs. That didn't stop RSPCA using dirty water in a hydrobath to make these dogs look really bad. One Dog called Simba was clipped with surgical clippers and later died from exposure caused pneumonia. NOTE: None of Geraldine Robertson's seized dogs had actual skin problems, only potential allegations in the future, according to RSPCA vets.

The RSPCA Intention was always to seize all of Geraldine Robertson's world famous pedigreed Neiger Poodles. 

Issues covered by the AFFIDAVIT on the Conduct of RSPCA 

1. Criminal Conspiracy to steal the Appellant's property, destroy her business and income and then deny her Justice in the Court. (manifest fraud and Collusion)
2. The Appellant spent 20 years building her World Famous Pedigreed Poodle blood lines..
3. Lies and their plausibility
4. Malice and Fraud by RSPCA - Intention to steal, deliberately concealing identities.
5. Submission on Fraud and Theft by RSPCA - Identification of valuable properties.
6. Submission on Fraud by RSPCA - Puppies born 
7. Submission on the RSPCA conduct and improper motives and behaviour.
8. RSPCA Money Motive - Deliberate "Legal" Theft.
9. The RSPCA attempted to ambush/prevent Geraldine Robertson's Appeal against the DPI forfeiture of her dogs. 
10. The RSPCA had no intention to return Geraldine Robertson's dogs and puppies. 
11. Due to the massive amount of perjury and His Honour’s stated willingness to consider this perjury the Appellant fears there will not be a just decision.  
12. The RSPCA conducted a campaign of harassment.  
13. RSPCA used the Poodle Club of Queensland to pervert the course of Justice
14. RSPCA Refused to provide access to Dogs and Records Seized (breach of section 151 of the Animal Care and Protection Act 2001) Refused proper identification.
15. Fraud and Theft of records by RSPCA 
16. Interference with witnesses (attempting to pervert the course of justice)

Issues covered by the AFFIDAVIT on the Evidence 

1. Would RSPCA Inspectors and RSPCA Veterinarians lie in court for $5million? 
2. Geraldine Robertson was performing her duty of care for her world famous Neiger poodles.
3. Lies about the reasons for the warrant
4. "The putrid smell was so bad it burnt the back of my throat". - Shayne Towers-Hammond.
5. Lies of Putrid Smell, urine & faeces in area left of entrance. (Can you believe an overpowering putrid smell in the house?)
6. Benji-Pet Kennel's puppies were not covered in faeces and urine. They were wet after playing in the rain and were put into holding pens when Geraldine Robertson saw the RSPCA arrive.
7. 104 Poodles were packed / compressed into 24 compartments for transport to RSPCA at Fairfield.
8. Another RSPCA fraud to the Court - "Felting and long wool is a problem for poodles"
9. BT5732  - ?? Ned had Maggots?? Another fabrication of evidence
10. A dog called Sandy had an ear infection. (Geraldine Robertson's dog Millie If it could be identified as Millie - ) bt5372  
12. Lies that the silt from the flooding rains was faeces and urine were just that - LIES.
13 Super woman Katie Heaton was able to do in just one hour what would take a normal person at least six hours to do.

Issues covered by the AFFIDAVIT on the Health of the Poodles 

1 RSPCA Veterinarians Records DID NOT identify any of Geraldine Robertson's world famous pedigree poodles. Breach of Sections 150 and 151 of the Animal Care and Protection Act 2001. 
2 Geraldine Robertson made every effort to identify her dogs. 
3. What the RSPCA Veterinarians have said
4. The Veterinarian Record Analysis
5. Surgical clipping by RSPCA killed Jason (Simba) with Pneumonia.
6. What the Veterinarians have SAID and HOW their evidence is a fabrication of LIES

Other people have had problems with RSPCA

RSPCA had demonstrated their interests are not for the care and protection of the dogs seized as intended under the Animal Care and Protection Act 2001 but for the purpose of profit making. The profits are achieved in these ways:-

1. RSPCA had presented a bill for $ 253.999.46 for care of the Geraldine's dogs from January 9 2008 to April 2008. RSPCA is seeking an income for the “care” of the Appellant’s dogs when the Veterinary records show that the dogs suffered from lack of care and required an enormous number of veterinary procedures caused by RSPCA’s lack of care in the months following seizure. Geraldine's dogs could live in luxury eating fillet steak and getting the best of everything for years on that sort of money. The Affidavit of Tracey Jackson where she demands the RSPCA be paid.
   

2. RSPCA will be seeking the legal costs of perusing their profit motive in Geraldine's  Appeal to get her poodles returned thus making a significant profit for their lawyers who act for RSPCA for the sole purpose of getting those legal costs.
   

3. RSPCA have raised Hundreds of thousands of dollars and valuable real properties as donations from the public for the care of the “poor malnourished neglected poodles” from immediately after seizure by defaming Geraldine and her poor poodles. 
   

4. RSPCA contacted dog food manufacturers who pledged many thousands $ in food for the “poor malnourished poodles”. RSPCA Vet Dr Ann Corvill, RSPCA spokesman Michael Beatty, Chief Inspector Michael Pecic and other employees in the weeks following 9 January 2008 in their telephone appeals, sought donations for the care of the Appellant’s poodles This was achieved by RSPCA's massive defaming of the Appellant in the media, on Internet web sites and in Internet forums continuously to date. (See RSPCA and Petrescue and other Internet sites). The Appellant’s dogs were in fact healthy, happy dogs at seizure.
   

5. The Poodle Club of Queensland inc sought donations from all the Poodle Clubs in Australia and others for donations of monies, food and equipment to care for Appellant’s Poodles. Sue Graham is the RSPCA and the Poodle Club of Queensland inc Standard Poodle Rescue Officer and the principle organizer of these appeals.

RSPCA became an incorporated trading entity within meaning and interpretation of section 51 (xx) of the Commonwealth Constitution and section 4 of the Trade Practices Act 1974 on 23 December 1999 within meaning and interpretation of law established by the Honourable High Court of Australia in R – v – Federal Court of Australia; ex parte W. A National Football League (1979) HCA 6 (1979) 143 CLR 190 or in the alternative; on 05 July 2002 within meaning and interpretation of law established by the Honourable Federal Court of Australia in Orion Pet Products Pty Ltd – v – Royal Society for Prevention of Cruelty to Animals (Vic) [2002] FCA 860 (5 July 2002) 

RSPCA  makes income from its activities which includes income from activities related to it seizure of animals. The Annual Report of RSPCA  details the following income:- 
a. $4.427 Million Dollars AUD was derived from trading activities of its animal shelters:- selling pets etc;
b. $2.559 Million Dollars was derived from retailing activities;
c. $3.939 Million Dollars was derived from sale of merchandise. 

RSPCA sells pets and in particular dogs calling the sale price “adoption price”. 

RSPCA  hereto were competitors of Geraldine's within the Pet Trade. Continuing to investigate, enforce and prosecute state law enacted by the Animal care and Protection Act 2001 would:-
(a) Contravene section 109 of the Commonwealth Constitution;
(b) Create serious conflict of interest;
(c) Create serious potential for abuse of authority.

RSPCA's actions in seizing Geraldine's dogs is an illegal act as it is a breach of the Trade Practices Act 1974. It is a use of market power and the Animal Care and Protection Act 2001 to deter and prevent the Appellant from engaging in competitive conduct in the dog market or any other market.

Blyth Labor Government Policy